Medication Requirements Tips

Prescribing, Labeling, Packaging, and Storage

  • Must be a written practitioner’s order for EACH prescription medication, OTC medication, PRN medication, and dietary supplements. Must be maintain in their file at all times.
  • Medications for internal consumption and medications for external application must be separated. If unable to do so, putting the external application medications in a sealable, plastic baggie.
  • The resident’s record needs to include a current list of the type and dosage of medications or supplements, directions for use, and any change in the resident’s condition (your eMAR is most likely capable of all this).

Documentation and Reviews

  • Resident medications must be reviewed by a physician or pharmacist within 30 days before or 30 days after their admission AND whenever there is a significant change in condition AND annually. Their annual physical will meet the requirement.
  • Every year (at least) a physician, pharmacist or RN must conduct an on-site review of the medication administration and medication storage system, as well as provide a written report of findings.
  • If a resident is on a psychotropic medication, they must be assessed by a physician, pharmacist, or RN at least quarterly to see if the medications is “working” as well as to document the presence of any side effects.

Disposal of Medications

  • Be sure to have a policy regarding disposal of medications (unused, discontinued, expired, etc.). There are some medications that cannot be returned to the pharmacy, so in those cases, you need to have a “plan of action” that remains locked to only the administrator or designee and two people (one being the administrator or designee) must witness, sign, and date a record of destruction.
  • Medications that cannot be returned to the pharmacy must be separated from other medication in current use in the facility. They must be stored in a locked area with access limited to the administrator or designed.

Staff Administration, Notification, and Reporting

  • A proof-of-use record is required for Schedule II drugs. This record must contain the date and time administered, the resident’s name, the practitioner’s name, dose, signature of the person administering the dose, and the remaining balance of the drug.  The administrator or designee must audit, sign, and date this record on a daily basis.
  • When a PRN medication is given, staff must “check” with the resident in 30 minutes and document their response.
  • Employees are not allowed to administer injectable, nebulizers, stomal, enteral, vaginal, or rectal medications unless they are an LPN or RN, without delegation.
  • All staff need to be made aware of the potential benefits and side effects of the medications… that’s why the side effects (pamphlets provided by the pharmacy) must be posted in their files.


Program Statements

Program Statements are an important part of your facility, resident care, and even for care teams. Even though they’re required by DHS 83 (and DHS 88), it is a wonderful opportunity to “show off” your assets and services in addition to proving your commitment to quality care.  The content should, at a minimum, include:

  • Staffing patterns
  • Available nursing
  • Resident capacity
  • CBRF classification
  • Resident groups served
  • Program goals and services
  • Services not provided

I suggest having specific sections within the Program Statement that are titled as follows:

  • Target Population – What will the primary resident group be?  If there is a variety of residents/diagnoses/needs, how will you ensure that the resident groups will be compatible with one another?
  • Capacity/Class – Note the classification, i.e. A, AS, ANA, C, CS, CNA.  How many beds?  Is it co-ed?  Briefly explain the layout of the house, i.e. how many bedrooms, how many bathrooms, smoking policy, stairs, the number of floors.
  • Admission Policy – If residents are accepted, what is the age range? Clarify the requirements. For example, must be ambulatory, semi-ambulatory, mentally and physically capable of responding to a fire or tornado alarm.  Include limitations in services, i.e. do you accept a resident in need of constant hospitalizations?  What about residents that are bed ridden? Perhaps you do not accept residents that have a history of property destruction.  What about residents who are physically or mentally abusive to others?  Perhaps you do not accept residents with a history of pyromania.  Please note that if you do accept residents that present these behaviors, preventative measures must be taken and documented.
  • Staff Levels and Training – What is the ratio of staff to residents?  Note, it must be adequate to meet the needs of the residents.  Do you provide 24-awake supervision?  If not, explain what you do provide.  What type of training does your staff undergo (take into consideration the minimum required by the DQA).
  • Program Goals – You may want to include specific goals such as promoting meeting goals in order to improve residents’ sense of self-confidence and self-worth, as well as developing or maintaining a meaningful level of community participation, as well as improving their level of independent functioning.
  • Program Rate – Here you list the daily per diem rate (unless required differently) OR you may just state that it’s disclosed in the placement agency’s contract. This might be necessary if the contracted rate changes year to year (and, since the Program Statement isn’t generally updated, we should ensure accuracy).

It is also imperative to list the Program Services.  I suggest including, at a minimum, the following:

  • Leisure Time and Community Activities.  Here you might include how you promote resident participation in activities and community integration.  This is the section where you might list what you provide for “outings” and group activities, as well as what you provide in the home.
  • Family Contacts.  Here you might detail how you promote family contacts whether by phone calls, visits, or letter writing, as well as the assistance you provide to the resident.
  • Nutrition. How do you meet the nutritional needs of the residents?  What type of meals, snacks, etc. do you provide?  Can you accommodate various diets or cultural needs?  These are questions that should be answered here.
  • Transportation.  Here you might include whether or not you provide transportation and, if so, to what?  If not, how do you assist with this?
  • Informational Services.  Detail what you provide in regards to keeping the treatment/care teams informed, i.e. temporary ISPs, comprehensive ISPs, progress reports, in-person meetings, telephone calls, etc.
  • Medication Monitoring.  How are medications administered, i.e. administered by staff with RN supervision, administered by staff AND the resident without RN supervision, or do the residents self-administer their medications?  What other services do you provide?  Additional groups with residents regarding medications?  List that here.
  • Money Management.  You might include information as to whether or not you manage resident money, what type of assistance you provide, or if you provide money management training.
  • Daily Living Skills Training.  Do you provide training in this area?  Do you promote independence and/or encourage residents to complete activities of daily living whether with or without assistance?  How do you do so?
  • Survival Skills, Social Skills, and Safety Training.  Promotion of skills, in this area, should provide opportunities for residents to learn to be self-sufficient and/or as independent as possible in order to foster growth in these areas or assistance in areas of vulnerability.

Be sure to provide your program statement to a new resident and their guardian (or legal representative), if applicable, before finalizing an agreement to provide care.  Also keep in mind that any change in your program statement must be submitted to the Department at least 30 days before its effective date.


Policies & Procedures

I always recommend facilities create at least four Policies & Procedures (or handbooks) to make available to all staff/caregivers and administration.  Medication Management and Administration policies are especially important because it’s a serious and big responsibility. Topics should include, but are not limited to:

  • Practitioner’s Orders
  • Medication Packaging
  • Reordering Medications Process
  • Medication Storage
  • Medication Documentation
  • Controlled Medication
  • Psychotropic Medication
  • Medication Errors
  • Medication Refusals
  • Resident Absences
  • Annual Reviews
  • Disposal of Medications

Emergency Preparedness is another important one.  Staff/caregivers should all know how to initiate the crisis management plan if they ever find themselves in an emergency.  I recommend including the following topics, at a minimum, in your policies and procedures: total evacuation locations, home environment, emergency food supply, winter storms, shelter-in-place, flood procedures, gas leak procedures, water shortages, electrical power outages, explosion procedures, bomb threats, chemical spills procedure, fire emergencies, and a post-crisis evaluation.

Don’t forget that there are other policies and procedures, especially those specific to your facility, which are of great importance.  Be sure that you have everything in place for not only your staff, but for your residents, too.


Resident Care and Services

Your services need to be designed and provided to allow the residents to increase or maintain independence.  They should teach and provide opportunities for the residents to increase their skills or to minimize natural decline in the ability to make wants and needs known.  The residents need the teaching and providing of opportunities to increase their abilities to get along with others and to strengthen personal relationships.

Staff should encourage and provide training for, as a part of the treatment plan, each resident to be responsible for the upkeep of his or her personal space and belongings.  This may include making their bed, dusting, sweeping, doing their own laundry, any additional household chores that may be assigned, meal preparation, etc.  Try a general “home chore schedule” and don’t forget to provide training in dressing, grooming, bathing, and eating as needed.  Note: These areas should be included in the resident’s ISP.

Residents should be allowed to set and meet goals improving their sense of self-confidence and self worth.  Further, residents should be encouraged to develop and/or maintain a meaningful level of community participation, as well as maintaining or improving on their level of independent functioning consistent with their individual abilities.

You should incorporate programs into an environment that provides for the integration of diverse physical, mental, social, and emotional expression.  Staff should teach and provide opportunities to increase the residents’ skills in grooming, hygiene, meal preparation, housekeeping tasks, budgeting, enhancement of social interaction abilities, counseling, community awareness experiences, medication management and symptom management, and evaluation.

Don’t forget to include all areas in the resident’s ISP and create attainable goals for them to achieve!

Resident Discharge Planning

Without discharge planning and proper relocation procedures (especially with developmentally disabled, elderly, and emotionally disturbed residents), relocation stress syndrome may develop.  Transferring from one environment to another causes physiological and psychological impairment that is actually known to cause serious illness (and can even be fatal).  However, the good news is, a change in routine and this syndrome can be mitigated with proper transition.

A facility may not discharge involuntarily unless any of the following apply:

  • The resident may initiate transfer or discharge at any time (within the terms of the admission/service agreement) as long as they are not on a Chapter 51 or a Chapter 55.
  • If a resident is incompetent, as found via Chapter 54, protests his or her stay, the facility must notify the care team and county protective services agency to obtain determination regarding whether or not to discharge.

The facility is not to discharge voluntarily, unless any of the following apply:

  • A 30-day written advance notice is give to the resident and their respective care care team, as well as the reason for the discharge (and possible alternatives).
  • The home provides assistance in relocating the resident and ensures that the new home or living arrangement is suitable to meet the needs of the resident before actually discharging them.

Note: There are reasons acceptable for involuntary discharge:

  • Nonpayment of charges as long as there is a reasonable opportunity to pay.
  • Care is required beyond what the facility can provide.
  • The resident requires care above and beyond the home’s program statement and terms of the admission/service agreement.
  • The resident requires medical care that the home cannot provide.
  • There is an immediate risk of serious harm to the health, safety, or welfare to the resident, other residents, or staff as documented (in the resident’s record).

What should the administrator do to help ease the adjustment?

  • Promptly inform the resident, i.e. provide the 30-day notice.
  • Assess the needs and preferences of the resident. Do not coerce, bribe, or retaliate.
  • Provide a tour; provide options (written and verbally); explain the benefits… and even the cons.
  • Allow them to ask questions; listen to their concerns.
  • Involve their care team.
  • Be sure to help them pack their belongings and try to make their new area similar to their old area.
  • Be sure to have their needs met at the new placement.
  • Monitor signs for added stress regarding the move.
  • Keep in mind their rights!
  • Prepare appropriate documentation and maintain all necessary documentation.
  • Orient staff appropriately.

Just remember that the facility is the resident’s home and moving is a “big deal” for them.  Make the move as comfortable as possible and display empathy throughout the entire process.


A resident change in condition is not only a “change” it is a process.

Many professionals require certain tools to do a job well.  As a caregiver, your valuable tool is observation.  By simply being attentive, you can gain a better understanding of how your residents feel and are able to recognize how their health, emotional, and social needs change.  You serve as the resident’s advocate and, in addition, fellow caregivers rely on you to observe and report any changes in a resident’s condition.

All caregivers are responsible for recognizing any changes with a resident and how to respond to those changes (it is not only your supervisor that is held accountable).  A change in condition is something different than what previously existed.  Significant change may mean one or more of the following:

  • Decline in a resident’s medical condition that results in long-term impairment
  • Decline in 2 or more activities of daily living
  • A pronounced decline in cognitive abilities or communication
  • Decline in behavior or mood to the point where things have become problematic

Resident documenting is important especially in regards to changes in condition.  The facility must notify the healthcare professional of the change in condition.  Document these changes and the healthcare visit as part of the resident’s record.  At all times, the caregivers must protect the rights and safety of the residents.  In order to do so effectively and properly, we must:

  • Fill out the Significant Change in Health Screening Instrument (DHS Form #F-62370).
  • Notify the physician and/or bring the resident to a medical professional (be sure to document these interactions and/or appointments).
  • Contact the treatment team (including the guardian or person responsible for the resident) and be sure to document and file the appropriate paperwork based on their policies and requests.
  • Fill out an Incident/Accident Report (if applicable).
  • Review and revise the Individual Service Plan (ISP) based on the assessment you will be conducting regarding the change (i.e., when there is a change in a resident’s needs, abilities, and physical or mental condition).
  • Review your written facility policy and procedure regarding the steps to take when there is an observed change of condition.
  • Report the significant change in condition to the Department.

It is a process.  It may seem time consuming.  It may seem tedious.  It may even seem overwhelming.  However, the ultimate goal is the proper care of your residents and it is imperative that you meet that goal.  **This was published in WALA’s newsletter.  Become a member now to read more fantastic articles!!


What exactly needs to be included in the Individual Service Plan??  The most important and main things we need to include are the (1) current status and observations; (2) services provided; (3) desired outcomes and measurable goals; and (4) providers.  It is important to note that the provider will often include staff, but will also sometimes include the physician, administrator, therapist, nutritionist, etc. based on the resident’s needs and wants.  Though the providers will vary by section, it is imperative to include who is responsible for delivering care to the resident.

Actual specifics will vary by population and by resident, but here is a general guide:

  • Personal care
    • Eating (including Special Diet and Choking Hazard)
    • Basic ADLs (including Oral Care, Dressing, Grooming, Bathing)
    • Toileting
  • Behavior Patters
    • Wandering/Elopement
    • Self-Abusive Behavior and/or Suicidal Tendencies
    • Property Destruction
    • Emergency Evacuation
    • Medication Compliance
    • Coping Skills/Mechanisms
    • Isolating
    • Lying
    • Manipulation
    • Stealing
    • Alcohol/Drug Dependence
    • Negative Attention Seeking
    • Sexual Deviation/Problems
    • Water Intoxication
    • Impulsivity
  • Physical Health
    • General Health
    • Chronic, Short-Term, and Recurring Illnesses
    • Physical Disabilities/Limitations
    • Hearing, Eyesight, and Dental
    • Nursing Procedures
  • Mental and Emotional Health
    • Self-Concept
    • Maturation
    • Attitude
    • Interaction with Others
    • Aggressive/Combative
    • Verbal Abuse/Physical Aggression
    • Anxiety
    • Obsessive-Compulsiveness
    • Insight
  • Social Participation
    • Interpersonal Relationships
    • Leisure Time Activities
    • Family Contacts
    • Community Integration
    • Religious and Other Group Activities
  • Independent Living Skills
    • Educational and Vocational Skills
    • Money Management
    • Communication Skills
    • Food/Meal Preparation
    • Community Outings
    • Instrumental ADLs (including Household Chores, Personal Room Upkeep, and Personal Laundry)

Also included must be the resident’s capacity for self-direction, as well as their capacity for self-care.  I know this list seems long and daunting, but things to remember… this list does not need to be included in every ISP… many items will not pertain to some of your residents.  Further, remember that once your ISP is complete, you will most likely not need to re-do the entire ISP.   Every year (for CBRFs) and every six-months (for AFHs), you will need to complete updates.

In addition, the entire treatment team must be involved in the completion of the ISP.  I recommend that you document what goals the resident AND the treatment team believe would be appropriate to include in the resident’s ISP.  Lastly, be sure to obtain a “signature and date” for each member of the treatment team (including the resident) acknowledging the ISP.